The present Policy ensures the principle of lawful, fair and transparent data processing and your right to information self-determination in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation, hereinafter “GDPR”) and Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information (hereinafter “Info Act”).
Phönix Budapest Ingatlankezelő Korlátolt Felelősségű Társaság (hereinafter: ‘Company’) – as the owner and operator of https://kastelyszirak.hu// website (hereinafter: Website) – hereinafter informs the visitors of the Webpage (hereinafter: ‘User’) by the present Data Privacy Policy about the terms and conditions of the data processing in the course of the Website and the services available on the Website, including the method, purpose, legal basis, duration of the data processing by the Company, the scope of the data processed, the possible data transfers, the person entitled to control or process the data, and the rights and remedies of the data subject with regard to the data processing.
We use personal data to arrange the room reservations, to participate in events and to send newsletters.
Contact details of the Company:
Phönix Budapest Ingatlankezelő Korlátolt Felelősségű Társaság
Registered seat: 1184 Budapest, Fonal utca 2/A.
Post address: 1184 Budapest, Fonal utca 2/A.
Represented by: Gregg Maughan, Rex Maughan and Péter Lenkey, solely
Cg: 01-09- 060211
Phone: +36 32 485 300
Fax: +36 32 485 285
The Company has not appointed a Data Protection Officer.
The declaration of an incapacitated minor and a minor under the age of 16 with limited legal capacity to act requires the consent of his or her legal representative.
Personal data shall be processed only for specified purposes, for the exercise of rights and the performance of obligations. The processing shall comply with this purpose at all stages and the collection and processing of data shall be fair.
Only that kind of personal data can be processed, which is indispensable for the purpose of the data processing, is adequate to achieve such purpose, only to the extent and for the duration necessary for such purpose.
I. Scope of personal data, purpose, legal basis and duration of data processing
The data processing of the Company’s activities is based on voluntary consent. In some cases, however, the processing, storage and transmission of some of the data provided is required by law, and we will notify our audience separately about it. We hereby call the attention of those, who provide data for the Company, that if they have not provided their own personal data, it is the data provider’s obligation to acquire the consent of the data subject.
- Room reservation
Users of the Website are entitled to make a reservation on the Website. The User shall provide his/her first and last name, telephone number, email address and payment method.
The legal basis of the data processing is the consent of the User, according to which the User gives his/her prior consent to the processing of his/her personal data by the Company under the conditions set out in this Policy, pursuant to Article 6 (1) a) of the GDPR.
The User has the right to withdraw his/her consent at any time, without prejudice to the lawfulness of the processing carried out on the basis of the consent prior to such withdrawal.
The duration of the data processing: the Company processes personal data until the commencement of the booking, as a separate paper registration is made upon check-in.
If the User does not provide his/her personal data, he/she cannot book a room on the website.
- Sending newsletters
The Company send newsletters containing news and offers to the subscribers electronically via e-mail in compliance with the provisions of the E-commerce Act and Act on the Commercial Advertising Activities. Subscription can be made at the website.
The Company processes the name and e-mail address of the User.
The legal basis of the data processing is the consent of the User, according to which the User gives his/her prior consent to the processing of his/her personal data by the Company under the conditions set out in this Policy, pursuant to Article 6 (1) a) of the GDPR.
The newsletters are not personalized, the Company sends notifications about the due discounts.
The User has the right to withdraw his/her consent at any time, by unsubscribing from the newsletter, without prejudice to the lawfulness of the processing carried out on the basis of the consent prior to such withdrawal. A direct link to unsubscribe is provided in each newsletter. The duration of the data processing: until unsubscribe from the newsletter.
- Wedding open day
The Company processes the data of those, who have subscribed to the wedding open day, in order to register the participants of the event.
The Company processes the name and telephone number of the User.
The legal basis of the data processing is the consent of the User, according to which the User gives his/her prior consent to the processing of his/her personal data by the Company under the conditions set out in this Policy, pursuant to Article 6 (1) a) of the GDPR.
The User has the right to withdraw his/her consent at any time, by unsubscribing from the newsletter, without prejudice to the lawfulness of the processing carried out on the basis of the consent prior to such withdrawal.
The duration of the data processing: – until the 5th day following the wedding day.
- Price offer request
Visitors to the Website are entitled to request a price offer on the Website. The User provides his/her first and last name, telephone number, email address, and the date and time of the arrival and departure.
The legal basis of the data processing is the consent of the User, according to which the User gives his/her prior consent to the processing of his/her personal data by the Company under the conditions set out in this Policy, pursuant to Article 6 (1) a) of the GDPR.
The User has the right to withdraw his/her consent at any time, by unsubscribing from the newsletter, without prejudice to the lawfulness of the processing carried out on the basis of the consent prior to such withdrawal.
The duration of the data processing: half year following the request of the price offer.
If the User does not provide his/her personal data, he/she cannot request price offer at the website.
- Cookies
Cookies are small text files containing a unique identifier that are stored on your computer or mobile device so that the device you use will be recognized when you visit a particular website or use an application. Cookies can only be used for the duration of a visit to a particular page or to measure how the User uses the service and content from time to time. Cookies help to display important features and functions used on the Website and mobile applications.
During the User’s visit to the Website, data relating to his/her visit, the domain name of the website from which the User was redirected to the Website’s homepage, the search engine, the type of the operating system, the IP address, the User’s ID, and other information transmitted by the http protocol may be automatically collected.
The cookie files used on the Website are not harmful to the User or to the computer/end device used by the User, therefore we recommend not to disable their operation in your browsers.
Cookie files used on the Website:
Name of the cookie: _ga
Function of the cookie: Google Analytics – Cookie to distinguish the users
Lifetime of the cookie: expiration time: 2 years
Name of the cookie _gid
Function of the cookie: Google Analytics – Cookie to distinguish the users
Lifetime of the cookie: expiration time: 24 hours
Name of the cookie: _gat
Function of the cookie: Google Analytics – cookies to reduce the request rate _dc_gtm_ < characteristics -id>
Lifetime of the cookie: expiration time: 1 minute
Name of the cookie: PHPSESSID
Function of the cookie: This cookie is essential for the use of the Website
Lifetime of the cookie: expiration time: 1 day
Name of the cookie: X-CSRF-TOKEN
Function of the cookie: Cookie to promote the safety of forms. Essential for the use of the Website.
Lifetime of the cookie: expiration time: 1 day
Name of the cookie: __cfuid
Function of the cookie: This cookie is used to identify particular customers behind a shared IP address.
Lifetime of the cookie: expiration time: 1 year
Name of the cookie: _icl_current_language
Function of the cookie: Cookie storing the current language of the website
Lifetime of the cookie: expiration time: 1 day
Name of the cookie: cookie_consent
Function of the cookie: Cookie storing the acceptance of the cookie information
Lifetime of the cookie: expiration time: 1 year
Name of the cookie: fr
Function of the cookie: Cookie necessary for the operation of Facebook share/like buttons on the website
Lifetime of the cookie: expiration time: 4 months
Name of the cookie: functional_cookie_category
Function of the cookie: Cookie storing the acceptance of functional cookies
Lifetime of the cookie: expiration time: 1 year
Name of the cookie: required_cookie_category
Function of the cookie: Cookie storing the acceptance of mandatory cookies
Lifetime of the cookie: expiration time: 1 year
Name of the cookie: statistics_cookie_category
Function of the cookie: Cookie storing the acceptance of statistic cookies
Lifetime of the cookie: expiration time: 1 year
Name of the cookie: viewedOuibounceModal
Function of the cookie: Cookie storing the view of the Exit pop-up windows
Lifetime of the cookie: expiration time: 1 day
Name of the cookie: wpml_referer_url
Function of the cookie: Storing the last requested URL on the front page.
Lifetime of the cookie: expiration time: 1 day
The User can change the method cookies are used through the browser, including blocking or deleting those, which are from the Website (and other Internet websites). For this purpose, browser settings shall be modified. The method of deletion is different depending on the used browser. Information regarding the deletion method of the cookie files is on the “Help” page of the chosen browser.
Further information about the cookie files is on the following main browser pages:
- Google Chrome
- Microsoft Edge
- Mozilla Firefox
- Microsoft Internet Explorer
- Opera
- Apple Safari
Detailed information on how to operate cookie files on a mobile phone or other mobile device are in the User Manual/User Instructions for the particular mobile phone or mobile device.
Restricting the use of cookie files on a particular device may make it impossible or very difficult to use the Website properly, for example, it may make it impossible to maintain the login period.
The legal basis of the data processing is the consent of the User, according to which the User gives his/her prior consent to the processing of his/her personal data by the Company under the conditions set out in this Policy, pursuant to Article 6 (1) a) of the GDPR. The User has the right to withdraw his/her consent at any time, by unsubscribing from the newsletter, without prejudice to the lawfulness of the processing carried out on the basis of the consent prior to such withdrawal. To withdraw, use the “Manage cookies” link at the bottom of the page.
II. Principle of accuracy
If there are any changes or modifications to the User’s data processed by the Company during the data processing period, we ask the User to notify us immediately using the contact details above.
III. Persons entitled to access the data
- Persons under the direct control of the Company
The personal data provided by the User may be accessed by the Company’s employees under the direct control of the Company within the performance of their duties, who shall process the data in accordance with the internal rules and procedures in force from time to time at the Company. For example, the Company’s employees who send out newsletters and promotional mailings will have access to your personal data for the purpose of case management.
- Data processors
When processing the User’s personal data, the Company transmits the personal data to the Website operator. The Website operator is: Hrenkó Informatika Korlátolt Felelősségű Társaság (4461 Nyírtelek, Petőfi Sándor street 4.)
IV. Data security measures
The Company stores the personal data provided by the User on a server located at the registered office of the Website Operator.
The Company/Processor ensures the security of the User’s data, the protection against unauthorised or unlawful processing, accidental loss, destruction or damage to the data, including the confidentiality, integrity, availability and resilience of the IT systems and tools used to process personal data, by applying technical and organisational measures appropriate to the level of risk.
V. Your rights regarding the data processing
1. Right to information/rectification
The User can request information from the Company, in writing or by email, via the contact details provided above, as to whether the Company is processing his/her personal data.
If such processing is in progress, the User has the right to request information from the Company about what personal data it processes, on what legal basis, for what purposes, from what source and for how long, and to whom, when, under what law, to which personal data it has granted access or to whom it has transferred his/her personal data, including in particular to third country recipients or international organisations.
The Company shall reply to the User’s request for information within a maximum of one month by letter or e-mail sent to the contact details provided by the User.
The User is entitled to access his/her personal data by the Company sending the personal data concerned to the User in writing or by e-mail.
2. Right to rectification
The User may request, in writing or by e-mail, through the Company’s contact details specified above, that the Company amend any of his/her personal data without delay or request the completion of his/her incomplete personal data. For example, he/she may change his/her e-mail address or password at any time.
The Company shall reply to the User’s request for information within a maximum of one month by letter or e-mail sent to the contact details provided by the User.
3. Right to erasure (‘right to be forgotten’)
The User may request from the Company through the contact details above in writing or via e-mail the erasure of personal data concerning him/her without undue delay where one of the following grounds applies:
- a) the personal data are no longer necessary in relation to the purposes for which they were processed by the Company;
- b) the User withdraws consent on which the processing is based, and where there is no other legal ground for the processing;
- c) the User objects to the processing and there are no overriding legitimate grounds for the processing,
- d) the personal data have been unlawfully processed by the Company;
- e) the personal data have to be erased for compliance with a legal obligation applicable to the Company;
- f) the personal data have been collected in relation to the offer of information society services to children.
The Company shall comply with the User’s request within a maximum of one month and shall notify the User thereof by letter sent to the contact details provided by the User.
If the Company has also transferred the User’s personal data to other companies, the Company will inform the other companies/processors within 30 days that the User has requested the deletion of the copy of his/her personal data.
4. Right to block/Right to restriction of processing
The User may request from the Company through the contact details above in writing or via e-mail to block his/her personal data or to restrict the data processing where one of the following grounds applies:
- a) the accuracy of the personal data is contested by the User; in this case the blocking/restriction shall be for a period enabling the Company to verify the accuracy of the personal data;
- b) the processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead;
- c) the Company no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defence of legal claims; or
- d) the User has objected to processing; in this case the limitation shall be for a period until the determination whether the legitimate grounds of the Company override those of the User.
In the event of blocking/restriction of data, such personal data may be processed, except for storage, only with the consent of the User or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for important public interest.
The blocking/restriction lasts as long as the reason indicated by the User requires the storage of the data.
- Right to data portability
The User may request from the Company through the contact details above in writing or via e-mail to receive the personal data concerning him/her, which he/she has provided to the Company, in a structured, commonly used and machine-readable format and the User has the right to transmit those data to another company without hindrance from the company to which the personal data have been provided, if the data processing is based on the User’s consent or contract and the data processing is carried out by automated means.
In exercising his/her right to data portability, the User shall have the right to have the personal data transmitted directly from one company to another, where technically feasible.
The Company shall comply with the User’s request within a maximum of one month and shall notify the User thereof by letter sent to the contact details provided by the User.
- Right to object
The User shall have the right to object through the contact details above in writing or via e-mail against the processing of his/her personal data based on the legitimate interests of the Company or a third party. In this case the Company shall no longer process his/her personal data unless the Company demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the User or for the establishment, exercise or defence of legal claims.
The User shall have the right to object through the contact details above in writing or via e-mail against the processing of his/her personal data for direct marketing purposes, in which case his/her personal data shall be no longer processed for such purposes.
The User may also express this objection by clicking on the “Unsubscribe from the newsletter” button in the newsletters/marketing letters sent by the Company via email, as a result of which the Company will no longer send the User a newsletter/marketing letter.
- Automated decision-making on individual cases, including profiling
The Company does not use decision-making based solely on automated processing, including profiling.
Should the Company introduce in the future a decision-making procedure based on such processing, the User will be duly informed in advance by email of the applied logic, method and essence of the decision and will be given the opportunity to request human intervention from the Company, to express his/her point of view or to object against the decision.
VI. Due processes regarding the data processing
In the event of unlawful data processing, before initiating legal proceedings, the User should first send a complaint to the Company, as this will allow the Company to rectify the unlawful situation on its own initiative.
By submitting a notification (complaint) to the supervisory authority, the User may initiate an investigation on the grounds that he/she has suffered or is at imminent risk of suffering a breach of rights in relation to the processing of his/her personal data. The name and contact details of the supervisory authority are as follows:
National Authority for Data Protection and Freedom of Information
Registered seat: 1125 Budapest, Szilágyi Erzsébet fasor 22/c
Post address: 1530 Budapest, Pf.: 5
E-mail: ugyfelszolgalat@naih.hu
Telephone: +36 (1) 391-1400
Fax: +36 (1) 391-1410
Website: www.naih.hu
In the event of unlawful data processing suffered by the User, the User may initiate civil litigation proceeding before a court. The court of law shall have jurisdiction to decide in the litigation. The litigation may also be brought before the court of law of the User’s domicile, at the User’s option. For a list of courts of law and their contact details, please click on the following link: http://birosag.hu/torvenyszekek.
VII. Review and amendment of the Policy
The circumstances of data processing may change from time to time, and the Company may decide at any time to add a new data processing purpose to its ongoing data processing, and therefore the Company reserves the right to amend this Policy at any time. The Company will notify the User of any changes to this Policy by email using one of the contact details provided by the User.
VIII. Legislation applicable to the data processing
The following legislation shall be applicable for the processing of the User’s personal data:
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR), the current text of which can be found here:
http://eur-lex.europa.eu/legal-content/HU/TXT/PDF/?uri=CELEX:32016R0679&rid=1
Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information („Info Act”), the current text of which can be found here:
http://net.jogtar.hu/jr/gen/hjegy_doc.cgi?docid=A1100112.TV
Act CVIII of 2001 on Electronic Commerce and on Information Society Services (“ISS Act”), the current text of which can be found here:
https://net.jogtar.hu/jogszabaly?docid=a0100108.tv
Act XLVIII of 2008 on Essential Conditions of and Certain Limitations to Business Advertising Activity, the current text of which can be found here::
https://net.jogtar.hu/jogszabaly?docid=A0800048.TV
